Subject: File No. S7-09-09
From: Saxon Birdsong
Affiliation: Baltimore-Washington Financial Advisors, Inc.

June 30, 2009

A thorough, unbiased and complete audit by experienced personnel is almost always effective at identifying fraud. However, we believe that the cost, ultimately borne by consumers, is excessive and less effective than some alternatives.

Most importantly, we believe that your proposal does not directly address the point of how investor fraud actually occurs; which is usually through fraudulent pricing and non-transparent reporting. We believe that legislation focused on the following would be less costly and far more effective:

• rules and procedures to make sure that ALL client assets are priced independently.
• require that clients' assets be held by an independent third party custodian
• require that specific assets held within all types of collective investments be fully disclosed to account holders
• require that persons who act as solicitors on behalf of advisors be required to carry out certain specific validation and verification and reporting procedures on a periodic basis.

We believe that all of these recommendations can be implemented within the existing regulatory framework.

Respectfully,

Saxon Birdsong
Baltimore-Washington Financial Advisors, Inc.
5950 Symphony Woods Road
Suite 600
Columbia, MD 21044